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Comments on Renewal of Waste Discharge Requirements (NPDES Permit No. CA0078441) for City of Dunsmuir Wastewater Treatment Plant, Shasta and Siskiyou Counties

Dear Mr. Warner:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the City of Dunsmuir Wastewater Treatment Plant (WWTP) in Shasta and Siskiyou Counties. CVCWA is a non-profit organization representing more than 50 publicly owned treatment works throughout the Central Valley Region in regulatory matters affecting surface water discharge, land application, and water reuse. We approach these matters with a perspective to balance environmental and economic interests consistent with state and federal law. Upon reviewing the Tentative Order, CVCWA has concerns with respect to several issues. First, CVCWA is concerned with the proposed application (or lack thereof) of appropriate dilution credits. Second, CVCWA is concerned with the reasonable potential analysis statements concerning ammonia. Third, CVCWA is concerned with the inclusion of a Compliance Schedule for a Inflow and Infiltration Reduction Project and Wet Weather Capacity Improvements in the City’s NPDES permit. CVCWA’s comments and recommendations with respect to these issues are provided herein.

Comments on the Tentative Waste Discharge Requirements Order R5-­‐2013-­‐XXXX (NPDES No. CA0079243), City of Lodi White Slough Water Pollution Control Facility, San Joaquin County

Dear Ms. Harder:

The Central Valley Clean Water Association (“CVCWA”) appreciates the opportunity to submit comments on the tentative Waste Discharge Requirements for the City of Lodi White Slough Water Pollution Control Facility (“Tentative Order”). CVCWA is a non-­‐profit association of public agencies located within the Central Valley region that provide wastewater collection, treatment, and water recycling services to millions of Central Valley residents and businesses. We approach these matters with the perspective of balancing environmental and economic interests consistent with state and federal law. In this spirit, we provide the following comments on the effluent limitation for temperature, reasonable potential determinations based on best professional judgment and the turbidity discussion in the Fact Sheet.